Gaspar v. Bayhon
REITERATIONFacts
The Antecedents: Complainant Eleazar B. Gaspar, a Court Interpreter, was the respondent in an administrative case (Adm. Matter No. P-92-670) filed by Remedios Antonino for conduct unbecoming of a government employee, intriguing against honor, less serious physical injuries, and acts of lasciviousness. Respondent Judge William H. Bayhon was the fifth Executive Judge tasked to investigate this case. Procedural History: The investigation of Adm. Matter No. P-92-670 was passed upon by several judges due to various circumstances, including motions to transfer venue and retirements. Judge Madayag deferred action due to a motion to transfer venue. Judge Logarta received evidence but the case was transferred to Manila. Judge de la Rosa scheduled hearings but retired before resolution. Judge Callejo inhibited himself. Finally, the case was referred to respondent Judge Bayhon. The Petition: Complainant Gaspar filed an administrative charge against Judge Bayhon for alleged failure to submit his report on the investigation of Adm. Matter No. P-92-670, which allegedly caused Judge Bayhon to be unable to receive his retirement benefits. The charge alleged malicious delay in the administration of justice and violation of the Code of Judicial Conduct.
Issue(s)
Whether the delay in the submission of the report on Adm. Matter No. P-92-670 constitutes malicious delay in the administration of justice. Whether respondent Judge Bayhon violated Rule 2, Canon 3, of the Code of Judicial Conduct.
Ruling
The administrative case against Judge William H. Bayhon is DISMISSED. Consequently, all retirement benefits to which he is entitled under the law are ordered RELEASED to him.
Ratio Decidendi
On the issue of malicious delay in the administration of justice: The Court held that the complainant's affidavit-complaint failed to disclose any allegation that the delay, if any, was borne of a malicious intent. Malice requires a deliberate evil intent and does not cover a mere voluntary act. The delay must be the result of a deliberate intent to inflict damage on either party. Since no specific act imputing malice to the respondent Judge was alleged or proven, the charge of malicious delay must fail. The Court reiterated the principle that a judge should not be blamed for the delay in the disposition of a case when the delay is beyond his control, especially in the absence of any showing that it was done in bad faith and intended to prejudice a party or was motivated by some ulterior ends, as held in San Pedro v. Salvador. On the alleged violation of Rule 2, Canon 3, of the Code of Judicial Conduct: The Court noted that respondent Judge Bayhon was the fifth Executive Judge assigned to the case, and he could not have been familiar with its antecedents. The records showed a complex procedural history involving transfers of venue and the retirement of previous judges. Judge Bayhon expedited the disposal of the case once it was referred to him, as acknowledged by the complainant himself. The delay in submitting the report was attributed to the unavailability of records and transcripts from previous proceedings, which were not under his control. The Court found that the delay was not attended with malice or ill motive, and imposing sanctions would serve no administrative purpose given that the respondent Judge had already compulsorily retired.
Main Doctrine
The charge of malicious delay in the administration of justice against a judge must fail if the complaint does not allege specific acts imputing malice and proving that the delay was deliberate and intended to inflict damage. Furthermore, a judge should not be blamed for delay beyond his control, especially in the absence of bad faith or ulterior motives.